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1 critical material scored · binding chokepoint: Silver (🇲🇽 MX 24% of mining) · 5 restrictive government measures on record
Fomicruz S.E. produces 1 of the 1 scored material above (Silver). For those, a supply restriction by the controlling country is a tailwind, not a headwind — the exposure is to disruption of a market this company supplies, not to a chokepoint it depends on. Every scored material here sits on its output side, so the Low · 39/100 band should be read as chokepoint salience, not as buyer vulnerability, and the Art. 24 input-side duties below are qualified accordingly.
Role from an explicit dossier role: tag or the producer-sector classifier behind the /minerals alternatives bench (one classifier on disk, generated 2026-10-07) — the same source the company page uses. A material the classifier has no entry for defaults to a buyer dependency, which can understate a producer's output side. Descriptive classification only: it enters no score.
The binding exposure is Silver — 🇲🇽 MX controls 24% of global mining. On this company's production footprint that scores 39/100 (partially hedged; global 43). The register holds 5 restrictive government measures touching this company's materials — each traced to its primary source below.
Peer rank · Silver Fomicruz S.E. is the 307th-most-exposed of the 331 named companies we track on 🇲🇽 MX's Silver chokepoint; the most-exposed is Omron Corporation (43/100). Ranked on the same footprint-adjusted buyer score as above — a relative read of an existing metric, not a new one.
Fomicruz S.E. ranks 420th of 462 verified mining metals companies, tied with 11 others at 39.
Same sector_primary, ranked on the company supply-risk index. Restricted to hand-verified dossiers — 132 further mining metals companies are tracked but auto-onboarded, and excluded here because their exposure list is a sector template rather than company research. A peer scoring lower is the useful read: it usually means a different production geography or a qualified second source.
Company supply-risk index 39/100 — the binding chokepoint dominates, with a modest add for exposure breadth across 1 scored material. Buyer-relative (first-order): weighted by where the company produces (AR 100%, estimated split — no cited source states these exact shares), applied across all materials — it does not yet trace each input to its specific sourcing step.
Disclosed production sites
Named plants and what they make, from the company's disclosures. Descriptive detail — the buyer score above is still driven by country-level footprint weights, not per-site material intensity.
> The exposure report this dossier powers is at > /intelligence/dossiers/fomicruz/report.
Fomicruz S.E. (Fomento Minero de Santa Cruz Sociedad del Estado) is the mining and hydrocarbons company of the Argentine province of Santa Cruz, created by the province in 1988 and wholly provincially owned. Its stated model is to originate and de-risk mining and oil projects — acquiring and adding geological/technical information on provincial ground — and then to partner with private capital for development and production, so that the province captures a share of the economic return rather than only royalties.
In practice that makes it a holder of minority equity in other operators' projects and a promotion vehicle for provincial geology, not a mine operator. Its longest-standing and only documented producing interest is a 7.5% stake in Cerro Vanguardia S.A., the Santa Cruz gold-silver operation that AngloGold Ashanti controls with the other 92.5%; Fomicruz was one of the original explorers of that ground in the late 1980s. The company also markets provincial exploration opportunities internationally (it presented Santa Cruz projects at PDAC 2026 in Toronto) and has signed royalty-reinvestment and partnership agreements with juniors and energy developers.
Its second business is hydrocarbons, where it is currently moving from passive shareholder toward operator: it is taking over conventional oil assets in the province's mature northern zone following YPF's withdrawal, and is responsible for remediating the legacy of eight decades of oil production there.
Fomicruz manufactures nothing and operates no mine, so its exposure is attributable equity output — its share of what its partners produce — not a bill-of-materials. That makes the exposure set narrow and shallow, and the honest read is that most of the sector default did not survive.
is a gold-primary operation whose vein orebodies carry large quantities of silver, mined and sold as a by-product at a scale of roughly 1.5–2.2 million ounces per year at 100% basis in the years AngloGold Ashanti has broken it out. Fomicruz's attributable share of that is 7.5%. This is a genuine but small and non-operating silver exposure: Fomicruz sets no production decision at the mine, and its silver is an incidental credit inside someone else's gold mine rather than a product it sells into a supply chain.
Vanguardia's output is overwhelmingly gold (179,000 oz in FY25 on AngloGold Ashanti's reporting). Gold is not in SCORED_MATERIALS (lib/minerals-supply-risk.ts, checked 2026-09-02), so the register cannot express what is economically most of this company's mining exposure. That is a coverage gap in our scoring vocabulary, not a finding that Fomicruz is low-risk — read the silver score as a partial view of the asset.
Dropped from the sector default: cobalt, copper, chromium, manganese, nickel, aluminium and niobium. None of these is produced by any Fomicruz-held asset, and Santa Cruz's producing mining geology is epithermal gold-silver, not base metals or ferroalloys. Nothing in the company's own materials or the provincial government's supports any of the seven.
Open lead — uranium and vanadium (deliberately not listed). The provincial government has publicly said it wants Fomicruz to become an active explorer of uranium and vanadium rather than only a shareholder in others' projects. Both are scored materials, so this would be a material change to the dossier. But an announced ambition is not an exposure: no drilled resource, reserve or production has been published behind either, and none is asserted here. Re-check when a resource statement or a named exploration partner appears.
Ranked by buyer-relative risk, highest first.
| Material | Controlled by | You | Global | Band | Art. 5 | Input share | Substitute | Laws | Trend |
|---|---|---|---|---|---|---|---|---|---|
| Silver | 🇲🇽 MX 24% mining | 39 | 43 | Low | — | Low | some | 5 | ▲ rising |
You = buyer-relative score (this company's disclosed footprint vs. the controller). Global = buyer-agnostic supply risk. Substitute = ease of swapping the material out (none = locked in). Input share = the material's disclosed magnitude in the company's input basket (HIGH/MED/LOW only where a public filing quantifies it; — = unrated). Descriptive effect-size, never scored.
Art. 5 = does the global top single-country share breach the EU's own CRMA Art. 5 diversification ceiling (no more than 65% of a strategic raw material from a single third country)? A conservative global-production PROXY for the EU-import denominator — descriptive only, sits beside the score, never merged into it (— = non-strategic material). Reg. (EU) 2024/1252 Art. 5 ↗
Per-material factor scoring on a 1–5 likelihood×impact scale, mapped to the Art. 24(2)(b) risk-factor framework. The headline score above is a portfolio RAG; this matrix is the assessment — it is where two companies with the same binding chokepoint diverge.
| Material | Geopolitical | Concentration | Price / market | Substitutability | Import reliance | Logistics · ESG · Supplier |
|---|---|---|---|---|---|---|
| Silver | 3 | 1 | 5 | 3 | 3 | company input |
1 = very low … 5 = very high — a standard supply-risk likelihood×impact scale (the form a competent authority expects for the Art. 24(2)(b) factor analysis, not a CRMA-numbered scale). Public-source factors are pre-filled from the engine's primary sources (USGS concentration, IPTM government actions, EU import data); the three rightmost factor categories need company / Tier-1 supplier data and are flagged as input under Art. 24(3). Hover any cell for its evidence.
Every new filing and every amendment (rate change, scope change, repeal) touching this company's materials in the window above. Append ?since=YYYY-MM-DD to this URL for a custom start date.
No filings or amendments in this window — the register has been quiet on this company's materials.
Restrictive government measures on this company's materials, newest first — each links to its primary government source.
The Art. 24(2)(c) vulnerability assessment, made explicit. For each leading exposure we model the move in this company's buyer-relative score under two distinct supply-disruption scenarios — the production footprint held fixed, only one lever moved at a time so each delta isolates one shock:
Under the 🇲🇽 MX shock, your disclosed plant carries the binding Silver exposure:
| Type | Scenario | Today | Stressed | Δ |
|---|---|---|---|---|
| Policy | Silver — 🇲🇽 MX escalates silver controls to a full export-licensing / ban regime | 39 | 47 | +8 |
| Concentration | Silver — 🇲🇽 MX becomes the single source for silver — the second source is lost (full 24%+ monopoly) | 39 | 65 | +26 |
A zero delta means that lever is already modelled at maximum on that material — today's score already prices it in. This is why the two scenarios are shown together: where a material's policy lever is already maxed (zero policy delta), the concentration shock still carries a real delta, and vice-versa. Each stressed score isolates its one lever; all other factors are held at current values.
No material crosses the significant-vulnerability threshold on the input side — every scored material here is one Fomicruz S.E. produces, and Art. 24 addresses the use of a strategic raw material as an input. The Art. 24(4) mitigation duty is not triggered on the public-source evidence; the mitigations below are precautionary.
Stated threshold (so the conclusion is reproducible and auditable): buyer-relative band ≥ High AND substitutability hard/none AND ≥ 1 in-force restrictive measure on the material, assessed over the 0 materials this company buys (the 1 it produces are excluded from the test and listed above). The CRMA does not fix a numeric definition of “significant”; the company may adopt a stricter or looser threshold and should record it here.
Proposed, announced or draft regulation that is not yet in force but would touch this company's at-risk materials if it passes. Forward-looking early-warning — the likelihood shown is an honest band derived from the legislative stage, not a forecast or a fabricated probability. Kept separate from the enacted register above: nothing here is law yet.
Likelihood band is derived deterministically from the legislative stage (announced → low; draft-published / in-consultation → moderate; passed-committee → elevated; passed-vote / awaiting-signature → high) — a reproducible, source-traceable proxy, not a probability estimate. Where shown, the modelled impact-if-passed re-uses the same buyer-relative stress engine as the enacted scenarios above: it holds this company's production footprint fixed and escalates the proposed measure to a full export-licensing / control regime — the conservative upper bound for a measure that may pass only as a partial cap. The delta is the move from today's score to that stressed score; companies with no modelled production footprint show no delta.
Forward-looking read on the binding chokepoint, from the recent trajectory of policy on these materials. Directional, not a forecast.
Every scored material here is one Fomicruz S.E. produces, so the Art. 24(4) buyer levers — qualify an alternative supplier, re-source, substitute the input — do not apply to this company. The output-side items below are what a concentrated producer's risk office actually acts on. We render them rather than a generic diversification list because a prescription addressed to the wrong side of the market is worse than none.
Under the EU Critical Raw Materials Act (Reg. (EU) 2024/1252), a Member State identifies the large companies (Art. 2(29): >500 employees and >€150M net worldwide turnover) using strategic raw materials to manufacture a listed strategic technology (batteries, renewables, hydrogen, traction motors, heat pumps, aircraft, data-storage equipment, robotics, drones, satellites, advanced chips). Those companies must, at least every three years and to the extent the information is available to them (Art. 24(2)), assess their strategic-raw-material supply chain. Where suppliers do not provide the data on request, the assessment may rely on the Commission's monitoring dashboard (Art. 20(4)) or other publicly available information (Art. 24(3)) — which is the evidence base this report assembles. Board reporting (Art. 24(5)) is voluntary unless the Member State mandates it (Art. 24(6)).
| CRMA provision | Obligation | Where addressed |
|---|---|---|
| Art. 24(1) | Member State identifies the company as in-scope (uses an SRM to make a listed strategic technology). | Scope & applicability |
| Art. 24(2)(a) | Map where the strategic raw materials are extracted, processed and recycled. | Exposure register + Supply-risk factor analysis |
| Art. 24(2)(b) | Analyse the factors that might affect supply. | Supply-risk factor analysis (factor matrix) + The laws that threaten it |
| Art. 24(2)(c) | Assess vulnerabilities to supply disruptions. | Stress test + significant-vulnerability conclusion |
| Art. 24(3) | Where supplier data is unavailable, rely on Commission (Art. 20(4)) / public sources. | This report's basis — see Methodology & sources |
| Art. 24(4) | Where significant vulnerabilities are found, assess diversifying or substituting. | Significant-vulnerability conclusion + Priority mitigations |
| Art. 24(5)–(6) | Report results, sources, significant risks and mitigations to the board. | This document — board-ready, PDF-exportable |
This report pre-fills the Art. 24(3) public-source half of the assessment. The company-specific inputs — employee/turnover thresholds, bill-of-materials volumes, the tiered supplier map, and formal board adoption — remain the company's to complete; they are flagged as “company input” where they appear.
Article 24 applies only when both size thresholds are met and a Member State has identified the company as making a listed strategic technology with strategic raw materials.
| Threshold test | This assessment |
|---|---|
| Average employees (last FY) > 500 | company input |
| Net worldwide turnover (last FY) > €150M | company input |
| Uses a strategic raw material as an input | company input — all 1 scored SRM here is one this company produces, not buys; input use is not evidenced by this assessment |
| Manufactures a listed strategic technology | mining-metals (confirm against Annex) |
| Formally identified by a Member State authority | company input |
Production-concentration figures: USGS Mineral Commodity Summaries 2026 + the production dataset behind each material page. Policy measures trace to the primary government sources below.
Each material's global supply-risk index blends five weighted factors: concentration of refining/processing (35%), active trade-control & policy pressure (25%), import reliance (15%), substitutability (15%), and price stress (10%). The buyer-relative score then scales the relational factors (concentration / policy / import) by this company's production-footprint alignment against each material's controlling country — bloc-neutral factors (substitutability, price) are left intact.
Caveats. The footprint is the company's assembly / manufacturing geography applied uniformly across all materials — a first-order proxy, not per-material input tracing. Scores are an analytical judgement on public data with a transparent weighting, not a market forecast or investment advice. Production shares reflect 2024-2025 figures and the policy position as of 2025-12-31; the register is continuously maintained and should be re-pulled against each new policy action.
MACROLENS · CICONIALABS · GEOPOLITICAL SUPPLY-RISK REPORT (EU CRMA ART. 20–25) · report generated 2026-10-07
Tip: the change log above defaults to the last 30 days. Append ?since=YYYY-MM-DD to this URL for a custom start date (e.g. ?since=2026-04-01).
This is a description of the actual automated pipeline (verifiable against this repo's own cron schedule), not a contractual commitment.